FOOD DEFENSE PLAN

INTRODUCTION

All food processing facilities need to address food defense. The first step is to develop
a functional food defense plan that assesses the existing security measures and risk
reduction programs already in place to reduce the likelihood that a terrorist could
adulterate or contaminate the finished product through contamination of raw materials,
in-process formulations or finished products at the end of the production process.

Although it may not appear that a small or very small establishment would be a target
for a terrorist activity, all establishments need to go through the exercise of assessing
where they may be vulnerable to terrorist activity and how they might reduce any risk
that exist. In the development of the food defense plan, the establishment will look at
where the vulnerabilities may arise. These may be from the outside through the
incoming raw materials, through unauthorized entry or through the water supply, or they
may be through internal means such as employees that have access to raw materials
and ingredients, in-process formulations or even finished products.

Forming a food defense team is a good place to start. Depending on the size and
structure of an establishment’s organization, team members may come from areas such
as management, security, quality assurance, human resources, maintenance,
engineering and even the FSIS inspectors.

After the establishment identifies potential vulnerabilities, it will then examine possible
risk-reduction methods such as the use of physical security or hardware (e.g., closed
circuit TV, alarms, doors, guards, access control systems), personnel security (e.g.,
background checks, colored hats, screening, training, awareness) or procedural security
(e.g., key control, having two persons present when raw materials are accessed,
testing).

Once the key vulnerabilities are addressed with risk-reduction methods, the
establishment needs to ensure that the risk-reduction techniques are being used (e.g.,
doors are kept locked, visitors are not allowed into the plant without an escort). This
verification should be documented, as well as periodic challenges to the system, and
reviews of the plan. Templates for these activities are included in the following plan
development model.
FOOD DEFENSE PLAN

Date of completion of this document: ___________

Food Defense Plan team members involved in completing this document:

______________________________________________________________
______________________________________________________________

BACKGROUND INFORMATION ON ESTABLISHMENT

Establishment # __________________

Establishment name: _______________________________________

Establishment location: ______________________________________

Contact 1 – Establishment Food Defense Plan

Name: ________________________________________
Phone number (daytime) __________________________
Phone number (off-hours) __________________________
Contact 2 – Establishment Food Defense Plan
Name: ________________________________________
Phone number (daytime) __________________________
Phone number (off-hours) __________________________

Primary products produced and shelf lives

Products – High to Low Volume Approximate shelf life Regulatory Authority

(days) (FSIS or FDA)

Number of Full and Part-time Employees (check one)

0 – 10 _____ 11 – 100 _____ 101 – 1,000 _____ > 1,000 _____

ADDITIONAL BACKGROUND INFORMATION ON ESTABLISHMENT

Do you have a select supplier program in place? A select supplier program includes
such criteria as sampling and testing by a long-term (one year) supplier, auditing to
verify their use of critical control points appropriately, documentation that indicates that
the supplier has a food defense plan, signed specification agreements, crisis
management programs, and stock recovery plans.

No: _____

Yes _____

If yes, approximate % raw material supply covered by select supplier program ____

Primary Raw Materials & Ingredients

Raw material or Package type(2) # lbs. finished QA checks on raw

ingredient(1) product/package(3) material/ingredient(4)

(1)
List your raw materials & ingredients, including water. It may be helpful to begin with major raw
materials and ingredients and work toward minor ones; however, note that sometimes minor raw
materials or ingredients can impact a large volume of finished products (this is important to understand in
developing food defense and is captured in column 3)
(2)
Package type should define how the raw material or ingredient is received, e.g., 2,000-pound combo
bin, 40-pound frozen block, 50-pound paper sack, 25-pound plastic pail, 5,000-pound bulk liquid
(3)
Estimate the number of pounds of finished product that could contain the raw material or ingredient,
using one package, e.g., 10,000 pounds raw ground beef from 2,000-pound combo, 500 pounds cooked
meat balls from 40-pound frozen block, 25,000 pounds of cooked chicken from 50-pound sack of corn
flour
(4)
Capture the QA checks done on the raw material and ingredients here, e.g., visual check for package
integrity, temperature reading, visual check for extraneous material
ADDITIONAL BACKGROUND INFORMATION ON ESTABLISHMENT

Cleaning and Sanitation Chemicals

Chemical(1) Package type(2) Storage(3)

(1)
List your chemicals being as specific as possible.
(2)
Package type should define how the chemical is received, e.g., 5,000-gallon bulk liquid, 55-gallon
drum; 40-pound liquid pail, 40-pound powder in plastic bag
(3)
Provide details on product storage, e.g., locked in cage, unlocked in storage room, locked in bulk-
storage tank

Cleaning & Sanitation Staff (check one)

Internal _____ External (contracted) _____ Both internal & external _____

If you use an external company for cleaning & sanitation, how many years have you
used this service? ___________ How many persons on the crew? ________

Controlling Access to the Establishment & Operations

Question Yes No
Do employees undergo background checks?
Do employees have identification badges for entry?
Are non-employees always escorted in the establishment?
Are truck drivers kept out of food storage & preparation areas?
Are barriers (locked doors, fences) in place to prevent unauthorized entry
into the grounds, building and operations areas?
Are limited-access areas secured?
ADDITIONAL BACKGROUND INFORMATION ON ESTABLISHMENT

Processing Steps & QA Checks

Step Yes or No(1) QA check(2) No QA check

Raw material receiving
Ingredient receiving
Raw material storage
Ingredient storage
Pre-mixing ingredients
Mixing, blending, tumbling
raw materials & ingredients
Grinding
Handling of raw materials by
people
Handling of ingredients by
people
In-process holding, e.g.,
surge tank, hopper
Product forming/shaping
Product injection or
tenderizing
Partial cooking
Full cooking (CCP)
Freezing
Packaging & boxing
Frozen storage
Refrigerated storage

(1)
Indicate whether or not your establishment has the processing step in any of your manufacturing
processes. Add additional steps as needed.
(2)
Capture the QA checks done at the specific processing step, if any, e.g., temperature reading, fat
analysis, visual check for extraneous material; if no QA check is done, check column 4
ANALYSIS OF BACKGROUND DATA FOR FOOD DEFENSE PLAN

After documenting the background information on employees, access to your facility

and operations, raw materials and ingredients, finished products, chemicals and
sanitation operations, and processing steps, you are now ready to answer some
additional questions in developing your food defense plan.

What are those areas or procedures in your facility and operation that you believe are
more vulnerable to possible attack by a terrorist (i.e., critical nodes)?

Area Reason for vulnerability Critical Node

Yes or No
Employees Lack of identification
Uncontrolled access within plant
Unsupervised activities

Non-employees Lack of identification

Uncontrolled access within plant
Unsupervised activities

Raw materials Suppliers not part of select supplier

program
Opportunity for unsupervised access
during receiving or storage

Ingredients Suppliers not part of select supplier

program
Opportunity for unsupervised access
during receiving or storage

Processing Unsupervised access to raw materials

during processing
Unsupervised access to ingredients during
processing
Unsupervised access to open hoppers,
tanks or other vessels during operations

Chemicals & Sanitation Unsupervised crew

Unsupervised access to raw materials,
ingredients & finished products during
cleaning operations
Unlocked storage of chemicals

Other Access to water supply

REDUCING RISKS AT CRITICAL NODES FOR THE FOOD DEFENSE PLAN

Now that you have identified some areas outside or inside your establishment, or
procedures used in daily operations that are more vulnerable than others, you can think
of ways to reduce the risk at that area or processing step. In order to do that, copy
those critical nodes identified above into column 2 below and complete the table. You
may not have vulnerabilities in all areas listed in the table (add additional rows if
needed).

Area Vulnerability Possible means to reduce the

vulnerability (countermeasures,
mitigation strategies)(1)
Employees

Non-employees

Raw materials

Ingredients

Processing

Chemicals &
Sanitation

Other

(1)
There currently is no list of countermeasures you may use; although industry task forces have
addressed common vulnerabilities; and these may be obtained through trade associations for the meat
and poultry industries. It is recommended that a team from the establishment evaluate the vulnerabilities
identified and think of the best way in their operation to reduce the risk. This is important because each
operation can be unique in terms of its physical design, number and types of employees, hours of
operation, raw materials and ingredients used in the operation, et cetera.
FUNCTIONAL FOOD DEFENSE PLAN

The Food Safety and Inspection Service has an expectation that each federally-
inspected meat and poultry establishment will have a functional food defense plan.
What you have just completed is a simplified vulnerability assessment and the
beginning of work to implement countermeasures against those vulnerabilities where
such a mitigation strategy is possible.

There are five key characteristics of a functional food defense plan:

Written: You are nearly complete as you answer the following questions and place this
completed document in a folder, electronic file or notebook entitled Food Defense Plan.
_____ check here once the plan is written and filed

Implemented: This means you are doing those written procedures in your plan that help
reduce the risk or vulnerability (e.g., checking name badges, wearing color-coded hats).
_____ check here if an Implementation Monitoring Schedule exists
(see following pages for example Implementation Monitoring Schedule)

Tested: Testing your plan means that someone challenges (e.g., by moving around the
plant without clearance) a component of the written plan to determine whether an
employee challenges the activity based on their training and understanding of food
defense.
_____ check here if an Test Schedule exists
(see following pages for example Test Schedule)

Assessed: The assessment of the plan may be best accomplished by a third-party

(from within or outside the company) expert that can help to determine if the plan is
adequate.
_____ check here if a third-party has assessed the plan

Maintained: You need to review the plan at some frequency (e.g., quarterly) to ensure it
covers the establishment’s activities, signing off on the review to demonstrate the
maintenance schedule for the plan.
_____ check here if a Maintenance Schedule exists
(see following pages for example Maintenance Schedule
 FOOD DEFENSE PLAN - IMPLEMENTATION MONITORING SCHEDULE

Date Identification of Observed Acceptable (A) Sign-off

Risk-Reduction Procedure(1) Needs Improvement (NI) (2) Signature

(1)
Write in the activity that is observed, e.g., badge checking, personnel only in designated area, outdoor
door secured
(2)
Acceptable = activity was occurring according to the written plan; Needs Improvement = activity was
not occurring according to the written plan – in this case, an action plan should be included to improve the
risk-reduction activity (see below)

NEEDS IMPROVEMENT ACTION PLAN - IMPLEMENTATION

Date Observed Risk-Reduction Needs Improvement Plan (1) Sign-off

Procedure Needing Improvement Signature

(1)
Write in the planned activity to strengthen the risk-reduction activity that was observed to need
improvement
 FOOD DEFENSE PLAN – TEST/CHALLENGE SCHEDULE

Date Risk-Reduction Procedure or Method Acceptable (A) Sign-off

that is Challenged in the Test(1) Needs Improvement (NI) (2) Signature

(1)
Write in the procedure or method that is challenged, e.g., outside door, personnel in designated area
only, secured ingredients or chemicals
(2)
Acceptable = risk-reduction procedure or method that was physically challenged; Needs Improvement
= procedure was not occurring as it should – in this case, an action plan should be included to improve
the risk-reduction procedure or method (see below)

NEEDS IMPROVEMENT ACTION PLAN – TEST/CHALLENGE

Date Challenged Risk-Reduction Needs Improvement Plan (1) Sign-off

Procedure Needing Improvement Signature

(1)
Write in the planned activity to strengthen the risk-reduction activity that was challenged and found to
need improvement
 FOOD DEFENSE PLAN - MAINTENANCE SCHEDULE

Date Reason for Review of Food Defense Plan(1) Sign-off

Signature

(1)
Write in the reason for the review, e.g., quarterly scheduled review, new product lines changing risk
profile, FSIS recommendations following audit

It also is a good idea to identify resources (contact name and phone numbers) that
would be contacted in the event that a terrorist activity does occur. Having these
resources identified in advance will decrease the reaction time.

Local Law Enforcement ________________________________________________

FBI Office ___________________________________________________________
State Health Agency ___________________________________________________
USDA Contact ________________________________________________________
FDA Contact _________________________________________________________
Trade Association Contact: ______________________________________________